The Clock is Ticking It’s time to prepare for PPACA Reporting Requirements! The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) to their employees. The additional reporting is intended to promote transparency with respect to health plan coverage and costs. It will also provide the government with information to administer other ACA mandates, such as the large employer shared responsibility penalty and the individual mandate. Filing Requirements Under both Sections 6055 and 6056, each reporting entity will be required to file all of the following with the IRS: • A separate statement for each individual who is provided minimum essential coverage (MEC) (for fully insured Applicable Large Employers (ALEs), this includes only full-time employees); and • A single transmittal form for all of the returns filed for a given calendar year. Under Code Section 6055, reporting entities will generally file forms 1094-B (a transmittal) and 1095-B (an information return). Under Code Section 6056, employers will file Forms 1094-C (a transmittal) and 1095-C (an information return) for each full-time employee for any month. Employers that are reporting under both sections 6055 and 6056 (e.g., selfinsured ALEs) will file using a combined reporting method, using Form 1094-C and Form 1095-C. EXPLAINED: 1095-C EXPLAINED: 1094-C Form 1095-C is provided to each full-time employee regardless of eligibility status and whether or not coverage was accepted. This form shows a month-by-month view of what coverage the employer offered. It also lists any safe harbors the employer elected. Form 1094-C is an aggregate of all of the 1095-C’s that were issued to employees. This file is submitted either electronically or via mail and informs the federal government of compliance. Reporting Responsibilities: Small Group (1-49) Large Group (50+) Forms 1095-B 1094-B 1095-C Self-Funded Employer Employer N/A Fully-Insured Carrier Carrier N/A Self-Funded N/A N/A Employer 1094-C Individual Statements N/A Employer: Form 1095-B N/A Carrier: Form 1095-B Employer Employer: Form 1095-C Fully-Insured Carrier Carrier Employer (does not complete Part III) Employer Employer: Form 1095-C By starting to track this information now, you’ll be prepared to file these forms on time. Key dates to remember: January 31, 2016 Every full-time employee must receive their 1095-C February 29, 2016 1094-C forms being submitted by mail are due March 31, 2016 1094-C forms being submitted electronically are due. If 250 or more 1095-C’s are issued the 1094-C and 1095-C must be sent electronically to the IRS.
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